1. This is an action under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000e-2.
2. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. Section 1331. The jurisdiction of this court is invoked to secure protection of and to redress deprivation of rights secured by 42 U.S.C. §2000e, et seq., providing for relief against discrimination in employment.
3. The unlawful employment practices alleged below were committed within Brevard County, Florida.

PARTIES
4. Plaintiffs are females who reside in Brevard County, Florida, and have at all times material herein resided in Brevard County, Florida.
5. Defendant is a Florida corporation, registered and doing business in the State of Florida. Defendant is an “employer” as that term is defined by Title VII of the Civil Rights Act of 1964.

STATEMENT OF CLAIM
6. Plaintiffs have retained the undersigned attorney and agreed to pay him a reasonable fee.
7. Plaintiffs have exhausted their administrative remedies prior to bringing this action.
8. Plaintiffs have complied with all conditions precedent prior to bringing this action.
9. Plaintiffs were employed by Defendant as fruit packers.
10. Plaintiffs were hired on or about September 1997 by Defendant.
11. Plaintiffs were laid off by Defendant on or about June 1998.

COUNT I
SEXUAL HARASSMENT AND HOSTILE WORK ENVIRONMENT
FEDERAL CLAIM
12. Plaintiffs reallege and incorporate paragraphs 1 through 11 of this Complaint as if set forth in full herein.
13. During their employment with Defendant, Plaintiffs were repeatedly subjected to sexual harassment by a co-worker. Plaintiffs, during their employment with Defendant, were also subjected to a hostile work environment by their supervisors, co-workers and the Defendants’ management.
14. The sexual harassment of Plaintiffs by their co-worker, Defendant’s employee, consisted of: unwanted and unsolicited touching and grabbing of the Plaintiffs’ persons of a sexual nature; lewd, disrespectful and sexually suggestive comments and gestures of a sexual nature directed toward Plaintiffs.
15. Plaintiffs repeatedly demanded of both the perpetrator of the sexual harassment and Defendant’s management that the sexual harassment cease. Plaintiffs repeatedly reported the sexual harassment to their immediate supervisor(s) and to the Defendant’s Plant Supervisor.
16. Defendant, thus apprised of the sexual harassment of Plaintiffs by Defendant’s employee, failed to take any remedial action to correct the problem. The sexual harassment of Plaintiffs did not cease after they brought the matter to the attention of Defendant’s management.
17. The hostile work environment, to which Plaintiffs were subjected by Defendant, consisted of: continued, and increasingly frequent sexual harassment directed toward Plaintiffs by their co-worker; harassment, and assault of Plaintiffs by said co-worker’s mother, who was also employed by Defendant; and battery of Plaintiff Silcox by said co-worker’s mother, Defendant’s employee.
18. Plaintiffs did not encourage, welcome or consent to the harassment described in paragraphs 14 and 17.
19. The acts alleged in paragraphs 13 through 17 constitute a violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §2000e-2, regarding unlawful employment practices.
20. Because of the actions of Defendant as alleged in this Complaint, Plaintiffs have suffered emotional distress and mental anguish.
21. Plaintiffs filed complaints with the U.S. Equal Employment Opportunity Commission and more than one hundred eighty (180) days have passed since the filing of said complaints. (Plaintiffs’ Charges of Discrimination attached hereto as Composite Exhibit “A”). On August 6, 1999, the EEOC issued to each of the Plaintiffs a Dismissal and Notice of Rights statement, and these statements are attached hereto as Composite Exhibit “B”.

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendant, for all damages to which they may be entitled, including, without limitation:
A. Back pay
B. Front pay
C. Damages for mental anguish
D. Damages for loss of dignity
E. Punitive damages
F. Reasonable attorney fees and costs of this action

COUNT II
RETALIATION – FEDERAL CLAIM
22. Plaintiff realleges and incorporates paragraphs 1 through 11, 13 through 18 and 21 of this Complaint as if set forth in full herein.
23. Plaintiffs gave Defendants notice of the sexual harassment described in this Complaint by reporting it to Defendant’s management. After Plaintiffs reported the harassment, they were unlawfully retaliated against for reporting the above described unlawful employment practices. Such retaliation on the part of Defendant included: the continued, and amplified, sexual harassment of Plaintiffs by their co-worker; assault of Plaintiffs by said co-worker and his mother, also an employee of Defendant, and battery of Plaintiff Silcox by said co-worker’s mother; the complete failure of Defendant’s management to take any remedial measures to eliminate the sexual harassment of Plaintiffs and the failure to rehire Plaintiffs for the next packing season..
24. Defendants had actual and constructive notice of the harassment and retaliation described in this Complaint because such harassment was pervasive and obvious and was in fact perpetrated by Defendants’ employees, including management employees.
25. Defendants failed to take remedial action in response to Plaintiff’s complaints regarding the sexual harassment, hostile work environment, and the retaliation to which Plaintiff was subjected.
26. The actions described in this Complaint constitute a violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. Section 2000e-3, regarding “other” unlawful employment practices.
27. Because of the actions of Defendant as alleged in this Complaint, Plaintiffs have suffered emotional distress and mental anguish.

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendant, for all damages to which they may be entitled, including, without limitation:
A. Back pay
B. Front pay
C. Damages for mental anguish
D. Damages for loss of dignity
E. Punitive damages
F. Reasonable attorney fees and costs of this action.

COUNT III
SEXUAL HARASSMENT AND HOSTILE WORK ENVIRONMENT
STATE CLAIM
28. Plaintiff realleges and incorporates paragraphs 1 through 11 and 13 through 18 of this Complaint as if set forth in full herein.
29. This action is brought pursuant to Section 760.10, Florida Statutes, the Florida Civil Rights Act. The acts alleged in this Complaint constitute a violation of that Act, which makes it unlawful for an employer to ” discriminate against any individual with respect to terms, conditions, or privileges of employment, because of such individual’s sex.”
30. Defendant is an “employer” as defined by the Florida Civil Rights Act.
31. Plaintiffs have each filed a Charge of Discrimination with the Florida Commission on Human Relations, alleging 1) discrimination by Defendant on the basis of their sex and 2) retaliation. More than one hundred eighty (180) days have passed since the filing of said complaints. Plaintiffs’ Charges of Discrimination are attached hereto as Composite Exhibit “C”.
32. Because of the actions of Defendant as alleged in this Complaint, Plaintiffs have suffered emotional distress and mental anguish.

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendant, for all damages to which they may be entitled, including, without limitation:
A. Back pay
B. Front pay
C. Damages for mental anguish
D. Damages for loss of dignity
E. Punitive damages
F. Reasonable attorney fees and costs of this action

COUNT IV
RETALIATION -STATE CLAIM
33. Plaintiff realleges and incorporates paragraphs 1 through 11, 13 though 18 and 31 of this Complaint as if set forth in full herein.
34. The acts alleged in this Complaint constitute a violation of Section 760.10(7), Florida Statutes, which states that “It is an unlawful employment practice for an employer…to discriminate against any person because that person has opposed any practice which is an unlawful employment practice under this section, or because that person has made a charge, testified, assisted in any manner in an investigation, proceeding, or hearing under this section.”
35. Because of the actions of Defendant as alleged in this Complaint, Plaintiffs have suffered emotional distress and mental anguish.

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendant, for all damages to which they may be entitled, including, without limitation:
A. Back pay
B. Front pay
C. Damages for mental anguish
F. Damages for loss of dignity
G. Punitive damages
F. Reasonable attorney fees and costs of this action

DEMAND FOR JURY TRIAL
Plaintiff demands a jury trial on all issues herein triable by jury.
DATED this _____day of _________________, 1999.